Our Website Uses Cookies

We and the third parties that provide content, functionality, or business services on our website may use cookies to collect information about your browsing activities in order to provide you with more relevant content and promotional materials, on and off the website, and help us understand your interests and improve the website.

Bill Chip advises and represents the owners and executives of emerging and established multinational enterprises in the design, execution, and defense of their global tax strategies. As a long-serving member of the OECD’s Business and Industry Advisory Committee (BIAC), Mr. Chip has been an active participant in the ongoing Base Erosion and Profit Shifting (BEPS) process that is reshaping the global tax planning landscape.

Mr. Chip’s clients are headquartered in the United States, the European Union, Asia, and Latin America and include companies in the financial services, life sciences, energy, and commodities industries.

A leading transfer pricing practitioner, Mr. Chip regularly manages global transfer pricing projects that cover planning, documentation, audit defense, and negotiation of Advance Pricing Agreements. With over 30 years of tax controversy experience, he has achieved favorable settlements of some of his client’s most difficult international tax controversies with the IRS at the examination and appeals level and in Competent Authority proceedings. He pioneered the use of Pre-Filing Agreements to settle complex tax treaty issues.

Prior to entering law school, Mr. Chip served as an officer in the U.S. Marine Corps, attaining the rank of Captain.

For a U.S. based biotech company, engineered a transfer of offshore intellectual property into a tax-advantaged jurisdiction and a subsequent spin-off and IPO.

For a Latin American multinational, designed and implemented a globally tax-efficient structure for licensing and lending to Latin American affiliates through the U.S. branch of a Spanish ETVE.

For a Middle Eastern chemical distribution company, designed and helped to implement a global marketing structure that minimized permanent establishment and transfer pricing risk.

For entrepreneurs in the banking and biotech industries, devised a structure for safely transforming foreign services and royalty income into low-taxed qualified dividend income with a credit for foreign income taxes at the entity level.

For the U.S. subsidiary of a large Asian industrial company, negotiated a “no change” settlement to an IRS-proposed equity reclassification of hundreds of millions of dollars of parent-guaranteed debt.

For the foreign owner of a U.S. affiliated group, negotiated the first-ever IRS Pre-Filing Agreement confirming that the owner satisfied the "limitation on benefits" test of a U.S. tax treaty.

For a U.S. bank seeking to acquire a troubled competitor, negotiated a unique IRS ruling that only bad debt losses realized in the first post-acquisition year would be subject to "built-in loss" limits on deductibility.

For a large EU institution, obtained an IRS ruling that the net operating losses of a liquidated U.S. subsidiary could be deducted by its U.S. branch, reversing an earlier, contrary published position of the IRS.

For a U.S. multinational, secured from the IRS a landmark private letter ruling holding that a foreign subsidiary's sale of stock in active foreign subsidiaries does not convert the selling corporation into a passive foreign investment company.

Pioneered a "virtual contract manufacturing" strategy that has been implemented by several Fortune 500 industrial companies.

For a large U.S. manufacturer, developed a supply-chain transfer pricing strategy for its foreign subsidiaries that accelerated utilization of U.S. net operating losses and reversal of associated valuation allowances.

For a major European bank, developed a plan for the tax-efficient combination of U.S. business activities conducted in branch and subsidiary form.

For a multinational agribusiness company, developed and supervised implementation of plans for the tax-efficient acquisition of a global competitor and the tax-efficient integration of legacy subsidiaries in Europe and the Americas.

For a state-owned, Middle Eastern oil company, developed an offshore strategy for the tax-efficient commercialization of intangible property.

For a multinational U.S. oil company, managed and brought to a successful conclusion income tax audits spanning 11 taxable years.

For a prominent national charity, advised and aided the Board of Directors in controlling the financial, tax, and reputational consequences of defalcations by a senior executive.

For a leading international financial institution, designed a partnership strategy for preservation of tax attributes of an acquired U.S. business.

WASHINGTON, DC, June 10, 2011 — Covington & Burling LLP received 123 individual mentions and 45 practice mentions in Chambers USA 2011. The guidebook, which ranks lawyers by state and national practice area, is designed to identify the most skilled legal practitioners based on the qualities most valued by clients.
Here are the Covington lawyers and practices ...

WASHINGTON, DC, June 16, 2010 — Covington & Burling LLP received 112 individual mentions and 44 practice mentions in Chambers USA 2010. The guidebook, which ranks lawyers by state and national practice area, is designed to identify the most skilled legal practitioners based on the qualities most valued by clients.
Here are the Covington lawyers and practices ...

WASHINGTON, DC, June 12, 2009 — Covington & Burling LLP received 100 individual mentions and 40 practice mentions in Chambers USA 2009. The guidebook, which ranks lawyers by state and national practice area, is designed to identify the most skilled legal practitioners based on the qualities most valued by clients.
Here are the Covington lawyers and practices ...

WASHINGTON, DC, June 16, 2008 — Covington & Burling LLP received 81 individual mentions and 45 practice mentions in the newly released 2008 Chambers USA. The guidebook, which ranks lawyers by state and national practice area, is designed to identify the most skilled legal practitioners based on the qualities most valued by clients.
Here are the Covington ...

WASHINGTON, DC, June 18, 2007 — Covington & Burling LLP received 44 practice mentions and 74 individual mentions in the newly released 2007 Chambers USA guidebook. The 2007 edition of Chambers USA attempts to identify the most skilled legal practitioners throughout the country based on the qualities most valued by clients. Covington attorneys have been ...

Covington & Burling LLP operates as a limited liability partnership worldwide, with the practice in England and Wales conducted by an affiliated
limited liability multinational partnership, Covington & Burling LLP, which is formed under the laws of the State of Delaware in the United States
and authorized and regulated by the Solicitors Regulation Authority with registration number 77071.
The practice in Johannesburg is conducted by an affiliated limited company Covington & Burling (Pty) Ltd. The practice in Dublin Ireland is through a general affiliated Irish partnership, Covington & Burling and authorized and regulated by the Law Society of Ireland with registration number F9013.